concept note on european union’s (eu’s) · pdf fileversion of 24.1.2017 page 1 of...

14
Version of 24.1.2017 Page 1 of 14 CONCEPT NOTE ON EUROPEAN UNION’S (EU’S) GENERALISED SYSTEM OF PREFERENCES (GSP) SCHEME OF SELF CERTIFICATION INTRODUCTION 1. The GSP is a unilateral tariff preference scheme on goods provided by developed countries to beneficiary developing countries (BDCs). These preferences could include both zero duty and concessional custom duty access to imported goods originating in the beneficiary developing countries. The major countries who grant GSP preferences to developing countries are Australia, Belarus, Canada, European Union (EU), Japan, Kazakhstan, New Zealand, Norway, Russia, Switzerland, Turkey and the United States (US). However, the GSPs granted by the EU and the US are the most comprehensive in terms of quantum of exports from developing countries. Many of the developed countries also provide additional tariff preferences to a specified class of developing countries with most providing the largest coverage of preferential or zero duty access to exports from Least Developed Countries (LDCs). 2. The GSP principle was conceptualized by the United Nations Conference on Trade and Development (UNCTAD) and adopted during the UNCTAD II Conference in New Delhi in 1968. The objective of the GSP as enunciated in Resolution 21 (ii) adopted at the UNCTAD II Conference are to a) to increase BDCs export earnings; b) to promote BDCs industrialization; and c) to accelerate BDCs rates of economic growth 3. The legal provisions for the grant of GSP is given in a 1978 Decision of the erstwhile GATT (General Agreement on Tariffs and Trade) called the “Enabling Clause”. 1 The specific provision of the GSP is given in para 2(a) of the Enabling Clause and is as under: Preferential tariff treatment accorded by developed contracting parties to products originating in developing countries in accordance with the Generalized System of Preferences EU GSP 1 Differential And More Favourable Treatment Reciprocity And Fuller Participation Of Developing Countries dated 28 November, 1978

Upload: vuongkien

Post on 03-Mar-2018

215 views

Category:

Documents


1 download

TRANSCRIPT

Version of 24.1.2017

Page 1 of 14

CONCEPT NOTE ON EUROPEAN UNION’S (EU’S) GENERALISED

SYSTEM OF PREFERENCES (GSP) SCHEME OF SELF CERTIFICATION

INTRODUCTION

1. The GSP is a unilateral tariff preference scheme on goods provided by developed

countries to beneficiary developing countries (BDCs). These preferences could include

both zero duty and concessional custom duty access to imported goods originating in the

beneficiary developing countries. The major countries who grant GSP preferences to

developing countries are Australia, Belarus, Canada, European Union (EU), Japan,

Kazakhstan, New Zealand, Norway, Russia, Switzerland, Turkey and the United States

(US). However, the GSPs granted by the EU and the US are the most comprehensive in

terms of quantum of exports from developing countries. Many of the developed countries

also provide additional tariff preferences to a specified class of developing countries with

most providing the largest coverage of preferential or zero duty access to exports from

Least Developed Countries (LDCs).

2. The GSP principle was conceptualized by the United Nations Conference on

Trade and Development (UNCTAD) and adopted during the UNCTAD II Conference in

New Delhi in 1968. The objective of the GSP as enunciated in Resolution 21 (ii) adopted

at the UNCTAD II Conference are to

a) to increase BDCs export earnings;

b) to promote BDCs industrialization; and

c) to accelerate BDCs rates of economic growth

3. The legal provisions for the grant of GSP is given in a 1978 Decision of the

erstwhile GATT (General Agreement on Tariffs and Trade) called the “Enabling

Clause”.1 The specific provision of the GSP is given in para 2(a) of the Enabling Clause

and is as under:

Preferential tariff treatment accorded by developed contracting parties to products

originating in developing countries in accordance with the Generalized System of

Preferences

EU GSP

1 Differential And More Favourable Treatment Reciprocity And Fuller Participation Of Developing Countries dated 28 November, 1978

Version of 24.1.2017

Page 2 of 14

4. The European Union or the EU (which was earlier known as the European

Economic Community) also grants GSP to beneficiary developing countries and was the

first to do so in 1971. The scheme is subjected to comprehensive revision every 10 years.

India is granted tariff preferences based on a “general arrangement” for developing

countries and is listed in Annex 1 of the regulation 978/2012 dated 25.10.2012.

However, the EU GSP has two “special arrangements” too which includes one for

beneficiary countries signing the agreements related to sustainable development and good

governance which is also known as GSP+ while the other is for the least developed

countries (LDCs) and is known by the term “Everything But Arms (EBA)”.

5. Hence, there are three main variants (arrangements) or tiers of the EU GSP

Scheme namely:-

i. The standard/general GSP arrangement, which offers tariff reductions or

elimination on identified products exported from beneficiary developing

countries. The coverage includes two thirds of all product categories.

ii. the "GSP+" enhanced preferences mean full removal of tariffs on essentially

the same product categories as those covered by the general arrangement. These

are granted to countries which ratify and implement 27 core international

conventions relating to human and labour rights, environment and good

governance;

iii. "Everything but Arms" (EBA) arrangement for least developed countries

(LDCs), which grants duty-free quota-free access to all products, except for arms

and ammunitions.

COVERAGE

6. The list of products which are eligible for tariff preferences for exports from India

is given in Annex V of the regulation 978/2012 dated 31.10.2012. It includes both

agricultural and industrial products and is listed under the HS classification. However, the

coverage of agricultural products is limited since it is sensitive for the EU. The

implementing EU regulation 1213/2012 dated 17 December, 2012 lists the suspension of

the tariff concessions on specific products for some beneficiary countries based on a trade

share criteria. This includes India and the duration of this suspension is from 1 January,

Version of 24.1.2017

Page 3 of 14

2014 to 31 December 2016. The tariff preferences for India that have been suspended are

three mineral products, organic and inorganic chemicals, other chemicals (some

fertilisers, dyes, essential oils, soaps, explosives etc), raw hides and skins, leather,

textiles, motor vehicles, bicycles, aircraft and ships. This was done since India’s exports

under the EU GSP exceeded the thresholds prescribed in the scheme. After the

suspension of preferences on some products, the coverage of the EU GSP Scheme for

India includes products such as animals and their products; dairy products; marine

products; plants; fruits and vegetables; coffee; spices; oilseeds; vegetable oil; processed

food; wines and spirits; tobacco products; some fertilisers; plastics; rubber; leather

articles; wood articles; clothing; footwear, glass; ceramics; gems & jewellery; iron &

steel; base metals; machinery; railway; instruments & appliances; watches; musical

instruments; furniture; toys & games; and miscellaneous manufactured articles..

7. In the EU Regulation 330/2016 dated 8 March, 2016; India has been graduated

out of other product categories namely minerals, chemicals (only organic and inorganic),

textiles, gems and jewellery, iron and steel, base metals and automotives (except

railways). The period of this suspension is from 1 January, 2017 until 31 December,

2019; and hence the coverage of EU GSP products for exports from India during this

period would include the product categories of animal products; vegetable products;

animal and vegetable fats and oils; prepared foodstuff; fertilisers, tanning/dyeing extracts;

essential oils and cosmetics; soaps; albuminoidal substances; photographic goods;

miscellaneous chemicals; plastics; rubber; leather; wood and articles therof; clothing;

footwear; headgear; umbrellas; articles of prepared feather; articles of stone; ceramics;

glassware; mechanical machinery; electrical machinery; railway equipment; optical

instruments; clocks; musical instruments; furniture, toys/ sports goods; and miscellaneous

manufactured articles.

THRESHOLDS FOR GRADUATION:

8. The thresholds for graduation prior to 2015 for any GSP beneficiary were that the

average imports over three consecutive years from them exceeds 17.5% of total EU GSP

imports. However, for textile and apparel, the threshold was 14.5% of total EU GSP

imports. Subsequently, the EU took out a regulation 1978/2015 dated 28 August, 2015

wherein these thresholds were revised. This was on account of some countries like China,

Ecuador, Maldives and Thailand being removed from the list of beneficiaries under the

Version of 24.1.2017

Page 4 of 14

EU GSP which led to the total base of GSP imports into EU decreasing significantly. The

revised thresholds for graduation as per Regulation 1978/2015 and effective from

1.1.2015 is as under:

i. 57% general

ii. 17.5% for plants (HS6), animal/vegetable fat & oils (HS15) and minerals (HS 25)

iii. 47.2% for textiles and clothing

This would mean that any beneficiary country would be graduated out of a product

category when this threshold is breached. India has been graduated out of many product

categories based on its exports going beyond these thresholds.

MARGIN OF PREFERENCE:

9. The products eligible for tariff preferences under EU GSP are categorized as

sensitive or non-sensitive. For the non-sensitive products, the tariff is eliminated under

the GSP. However, for sensitive products, the ad valorem duty is reduced by 3.5%

percentage points while the specific duty is reduced by 30%. For example, in the case of

a sensitive product an ad-valorem duty of say 10% is reduced to 6.5% while a specific

duty of say €100/kg is reduced to €70/kg. However, for textiles and apparel, both the ad

valorem and specific duty are reduced by 20% i.e. to 8% and €80/kg respectively in the

same example above.

RULES OF ORIGIN:

10. In order for goods to benefit from the customs duty preferences under the EU

GSP upon importation into the EU, three conditions must be fulfilled:

i. the goods must originate in a beneficiary country in accordance with the EU GSP

RoO;

ii. during transportation from a beneficiary country to the EU, the goods must not be

altered, transformed or subjected to operations other than operations performed in

order to preserve them in good condition; and

iii. a valid proof of origin must be submitted (certificate of origin Form A, issued by the

competent authorities in the beneficiary country, or invoice declaration, or as of 1

January 2017, a “statement on origin” on a commercial document).

Version of 24.1.2017

Page 5 of 14

11. The rules of origin under the EU GSP is given in the Regulation No 1063/2010

dated 18 November, 2010. There are no general rules of origin and the EU GSP uses the

product specific rules or PSRs. These rules determine the origin of the product which is

eligible for customs duty preferences for exports to the EU under the GSP Scheme. The

agencies certifying the origin of a product under the EU GSP have to ensure that the

exporter from the beneficiary exporter complies with these rules for exports under the EU

GSP. These rules vary for different products and include criteria such as wholly

originating, change in tariff classification (CTC), value addition, technical processes etc.

12. The rules also lists out the criteria for wholly originating (WO) products. If any of

these criteria are met, then one does not have to apply the product specific rules or PSRs.

A WO product is assumed to have originated from the beneficiary country without any

processing or inputs having been carried out or used from a another country. The key

elements of the WO criteria under the EU GSP are:

a) Mineral products extracted from the soil or seabed;

b) plants and vegetable products grown or harvested there ;

c) live animals born and raised there;

d) products from live animals raised there ;

e) products from slaughtered animals born and raised there ;

f) products obtained by hunting or fishing conducted there;

g) products of aquaculture where the fish, crustaceans and molluscs are born and

raised there;

h) products of sea fishing and other products taken from the sea outside any

territorial sea by its vessels;

i) products made on board its factory ships exclusively from the products referred to

in point;

j) used articles collected there fit only for the recovery of raw materials

k) waste and scrap resulting from manufacturing operations conducted there;

l) products extracted from the seabed or below the seabed which is situated outside

any territorial sea but where it has exclusive exploitation rights;

m) goods produced there exclusively from products specified in points (a) to (l)

13. Moreover, there are a set of minimal operations or insufficient processing

stipulated under the EU GSP which by themselves would not confer the originating

Version of 24.1.2017

Page 6 of 14

criteria despite the PSR having been fulfilled. Therefore, it is important that operations

beyond this minimal list be carried out in India for these products to be eligible for GSP

preferences. Some of these minimal operations or insufficient processing are:

a) preserving operations to ensure that the products remain in good condition during

transport and storage;

b) breaking-up and assembly of packages;

c) washing, cleaning; removal of dust, oxide, oil, paint or other coverings;

d) ironing or pressing of textiles and textile articles;

e) simple painting and polishing operations;

f) husking and partial or total milling of rice; polishing and glazing of cereals and rice;

g) operations to colour or flavour sugar or form sugar lumps; partial or total milling of

crystal sugar;

h) peeling, stoning and shelling, of fruits, nuts and vegetables

i) sharpening, simple grinding or simple cutting;

j) sifting, screening, sorting, classifying, grading, matching (including the making-up

of sets of articles);

k) simple placing in bottles, cans, flasks, bags, cases, boxes, fixing on cards or boards

and all other simple packaging operations;

l) affixing or printing marks, labels, logos and other like distinguishing signs on

products or their packaging;

m) simple mixing of products, whether or not of different kinds; mixing of sugar with

any material;

n) simple addition of water or dilution or dehydratation or denaturation of products

14. The value addition criteria for the PSRs under the EU stipulates the percentage of

the non-originating material to the ex-works price of the export product. There are no

specific options such as step up and step down method as is prevalent in some of India’s

Free Trade Agreements (FTAs). Some of the typical value addition criteria used in the

PSRs under EU GSP are:

a. Value of non-originating materials does not exceed “X” % of ex-works price

b. Value from same or specific headings does not exceed “Y”% of ex-works price

15. The change in tariff classification (CTC) under the EU GSP consists of changes at

the heading (HS 4 digit) and sub-heading (HS 6 digit) level. Some of the typical CTC

rules used in the EU GSP are the following:

a. Manufacture from materials of any heading

Version of 24.1.2017

Page 7 of 14

b. Manufacture from materials of any sub-heading

16. Certain PSRs under the EU GSP also have technical processes specified in them

for achieving the requisite originating criteria for exports to EU. Some of are specific to

products categories such as :

a. Wood products – planing, sanding, end jointing and slicing

b. Textiles – weaving, spinning, printing and dyeing

EU SELF-CERTIFICATION:

17. Under the proposed EU GSP self-certification scheme, the exports with

consignment value > € 6000 under the EU GSP would need to be self-certified by the

exporter (rather than by the approved agencies) from I January, 2017 onwards. This

would be done through a “statement on origin” which has to be made out on a

commercial document such as commercial invoice, packing list and delivery notice. If an

invoice value is < €6000 but is part of a consignment whose value is >€6000, a REX

number in the “statement on origin” would be required. Moreover, in case an invoice

consists of multiple consignments whose total value is > €6000, a REX number would be

required in the “statement on origin”. There is a transition period for the implementation

of this scheme with an initial period of 1 year wherein the 3rd party certification under

Form A can be used. However, once an exporter registers with the competent authority

(Local User for Registration), he would need to issue the “statement on origin” and would

not have the option of using Form A. The registration of exporters is done through the

EU’s Registered Exporter (REX) system.

18. The implementation of the EU GSP self-certification system has been entrusted

to a number of agencies in the beneficiary developing countries. In this context, the EU

has defined two types of competent agencies for each BDC as under:

i. Competent authority for administrative cooperation (ADC)

ii. Competent authority for registration (REG)

Each of these competent authority would have atleast one local administrator.

19. Hence, there are two sets of local administrators for each beneficiary country as

under:

Version of 24.1.2017

Page 8 of 14

i. Local administrator for administrative cooperation (ADC)

ii. Local administrator for registration (REG)

These Local Administrators are provided access to the EU’s Registered Exporter or REX

system. They in turn will create Local User(s) under them who would invariably be their

regional and branch offices. In the context of the EU GSP self-certification, it is the Local

Users for Registration to whom the exporters would need to apply for registration under

the REX system.

20. India has designated the following agencies who would perform their roles:

i. Local Administrator for administrative cooperation (ADC): The Department

of Commerce, Government of India which would be agency that would perform

this role.

ii. Local Administrators for Registration (REG): India has designated 16 agencies

who would perform this role. Their contact details is given in Appendix 1. They

would be responsible for accessing the EU system and registering the local users.

iii. Local Users for Registration (REG): The designated regional and branch offices

of the Local Administrators for REG would be the agencies who would perform

this task. They who would register the exporters and allot them the REX

(Registered Exporter) number. The updated list of the local users for registration

would be provided once it is available.

The office of the DGFT would be notifying the list of all Local Administrators and Local

Users from time to time.

21. All the exporters who are exporting or intend to export to EU under GSP would

need to register on the Registered Exporter (REX) System of the European Commission.

The exporter would need to fill in the pre application form which is available at

https://customs.ec.europa.eu/rex-pa-ui/

One of the cells in this application relates to the TIN number. For India, this would be in

the format of 12 digits namely “IN followed by the 10 digit IEC number”. A printout of

this form (format as given in Annexure 2) would then need to be taken and the exporter

would need to get this signed by his authorised signatory. If the details filled in by the

exporter are different from that in the IEC, necessary documentary proof may be

produced by the exporter to the local user for registration for justifying this departure

from the IEC details.

Version of 24.1.2017

Page 9 of 14

22. A REX number would be allotted to the exporters once the registration is

completed. For India, the format of the 20 digit REX number would be as under:

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

I N R E X IEC number Alphabets

assigned to

local Admn

Number of

the local user

IN denotes

India

Denotes

REX

number

10 digit IEC (Importer Exporter Code)

number of exporter

For ex:

EC for

EIC; DG

for DGFT

Ranges

from 001 to

999

After receiving the REX number, the exporter would be in a position to issue the

“statement on origin” on his own. He does not have to subsequently go to any of the

agencies for issuance of a certificate of origin (Form A). However, he can avail of the

services of the local administrators and local users in cases where he has specific queries.

Moreover, after registration, the exporter has to export under the EU GSP by only using

the “statement on origin” (and not Form A).

23. Under the EU GSP self-certification, the exporter can issue a “statement on

origin” which would be printed on a commercial document such as the invoice. The

format of the statement on origin is as under:

The exporter “REX Number of exporter” of the products covered by this document

declares that, except where otherwise clearly indicated, these products are of Indian

preferential origin according to rules of origin of the Generalised System of

Preferences of the European Union and that the origin criterion met is .

P (if wholly obtained)

W“4 digit HS code of export product” if sufficiently worked or processed

EU/ Norway/ Switzerland/ Turkey cumulation

Regional cumulation (in case of SAARC cumulation)

24. The exporters have the responsibility to ensure that the “statement on origin”

complies with the requisite rules of origin i.e. WO, PSR, cumulation etc. In case of any

doubt, the exporters can avail of the services of the local administrators and users who

may levy a fee commensurate with the cost of services rendered. A copy of the statement

on origin has to be sent to the Local User for Registration (REG) and the exporter would

need to maintain the requisite records of these statements of origin and supporting

documents for a period of 3 years beginning from the end of the calendar year when the

export had occurred.

25. In the eventuality of any request for verification from the EU, the Department of

Commerce would decide on the Local Administrator/ Local User for Registration (REG)

Version of 24.1.2017

Page 10 of 14

which would conduct this verification. The agencies may charge a fee for this verification

which is reasonable and commensurate with the cost of services rendered.

26. The role of the apex chambers of commerce and industry, export promotion

councils, commodity boards, development authorities etc would be the following:

i. Conduct outreaches and training programmes across the country to make the

exporters aware of the EU GSP self-certification scheme.

ii. Ensure that exporters (both existing and those intending to export to EU) register

themselves on the REX system by going to the relevant Local User for

Registration (REG)

27. The office of the DGFT has issued a Public Notice No 51 dated 30.12.2016 which

provides the legal framework for the implementation of the EU GSP self-certification in

India. One of the key responsibilities of the exporter is to provide the details of the

“statement on origin” to the Local Administrator / User for registration (REG) as under:

i. HS Code,

ii. Description,

iii. Document No/ date on which “statement on origin” is made out,

iv. FOB value of exports (in US $),

v. destination port,

vi. destination of export

vii. Origin Criteria i.e. “P” or “W with 4 digit HS Code”

Version of 24.1.2017

Page 11 of 14

Annexure 1: List of India’s Local Administrators

S. No. Local Administrator Name of Nodal

officer

Designation e-mail address Contact No.

1 Textiles Committee Mr. S. Ulaganathan Director (EP&QA) [email protected],

[email protected]

0091-9444009979

0091-44-24615901,

0091-44-24610887

2 Directorate General of

Foreign Trade (DGFT)

Mr. S.P. Roy Joint DGFT [email protected] 0091-8800523645

0091-11-23062240

3 Office of the Development

Commissioner (Handicrafts)

Mr. A.K. Mohanty Assistant Director

(International

Marketing)

[email protected] 0091-8797387435

0091-11-26178675

4 Kandla Special Economic

Zone (SEZ)

Mr. Rajesh Kumar Deputy Development

Commissioner

[email protected] 0091-9867641440

0091-2836-252273

5 Noida SEZ Mr. Ram Baboo Assistant Development

Commissioner

[email protected] 0091-9810631365

6 SEEPZ SEZ, Mumbai Mr. V.P. Shukla Joint Development

Commissioner

[email protected] 0091-9920077698

0091-22-28294729

7 Central Silk Board Mr. P.M. Pandi Deputy Director

(Inspection)

[email protected]

[email protected]

0091-9481855373

0091-80-23120274

0091-80-23421144

8 The Marine Products Export

Development Authority

(MPEDA)

Mr. Premdev K.V. Deputy Director

(Statistics)

premdev@mpeda. gov.in 0091-9447450824

0091-484-2312838

9 Cochin SEZ Mr. Saju K.

Surendran

Deputy Development

Commissioner

[email protected] 0091-9711433050

0091-484-2413235

10 Export Inspection Council Mr. Vivek R. Bidwai Deputy Director tech2@eicindia. gov.in 9850555147

Version of 24.1.2017

Page 12 of 14

S. No. Local Administrator Name of Nodal

officer

Designation e-mail address Contact No.

(EIC) 0091-11-23365540

0091-11-23341263

0091-11-23748189

11 Spices Board Mr. Anan Debbarma Assistant Director

[email protected] 0091-7034757782

0091-484-2333610

12 MEPZ SEZ Mr. S. Parasuraman Executive Assistant [email protected] 0091-9444213018

0091-44-22623240

13 Coir Board Mr. P.R. Ajithkumar Director (Marketing) [email protected] 0091-9400144561

0091-484-2351900

14 Visakhapatnam SEZ Mr.T.G.K.

Jagannadham

Deputy Development

Commissioner

[email protected] 0091-8130602660

0091-406-7304611

15 Falta SEZ Mr. Ratan Nandan Assistant Development

Commissioner

[email protected] 0091-9432405138

0091-33-22872263

0091-33-22877923

0091-33-22874092

16 Tobacco Board Mr. Manoj Reddy Manager (Marketing

& Exports)

[email protected] 0091-9866076407

0091-863-2358068

Version of 24.1.2017

Page 13 of 14

Annexure 2: Format of the application for Registration

APPLICATION TO BECOME A REGISTERED EXPORTER

For the purpose of schemes of generalised tariff preferences of the European Union,

Norway, Switzerland and Turkey (2)

1. Exporter’s name, full address and country. EORI or TIN (3)

2. Contact details including telephone and fax number as well as e-mail address where

available

3. Specify whether the main activity is producing or trading.

4. Indicative description of goods which qualify for preferential treatment, including

indicative list of harmonised System headings (or chapters where goods traded fall

withing more than 20 Harmonised System headings).

5. Undertakings to be given by an exporter

The undersigned hereby:

Declares that the above details are correct.

Certifies that no previous registration has been revoked, conversely, certifies that

the situation which led to any such revocation has been remedied.

Undertakes to make out statements on origin only for goods which qualify for

preferential treatment and comply with the origin rules specified for those goods in

the Generalised System of Preferences.

Undertakes to maintain appropriate commercial accounting records for

production/supply of goods qualifying for preferential treatment and to keep them

for at least three years from the end of the calendar year in which the statement on

origin was made out.

Undertakes to cooperate with the competent authority.

Undertakes to accept any checks on the accuracy of his statements on origin

2 The present application form is common to the GSP Schemes of four entities, the Union (EU), Norway, Switzerland and Turkey (the

entities). Please note, however, that the respective GSP schemes of these entities may differ in terms of country and product coverage. Consequently, a given registration will only be effective for the purpose of exports under the GSP scheme(s) that consider(s) your

country as a beneficiary country. 3 The indication of EORI number is mandatory for EU exporters and re-consignors. For exporters in beneficiary countries. Norway,

Switzerland and Turkey, the indication of TIN is mandatory.

Version of 24.1.2017

Page 14 of 14

including verification of accounting records and visits to his premises by the

European Commission or Member States authorities, as well as the authorities of

Norway, Switzerland and Turkey (applicable only to exporters in beneficiary

countries).

Undertakes to request his removal from the system, should he no longer meet the

conditions for exporting any goods under the scheme.

Undertakes to request his removal from the system, should he no longer intend to

export such goods under the scheme.

......................................................................................................................................................

Place, date, signature of authorised signatory, name and job title

6. Prior specific and informed consent of exporter to the publication of his data on the public

website

The undersigned is hereby informed that the information supplied in this application may

be disclosed to the public via the public website. The undersigned accepts the publication

and disclosure of this information via the public website. The undersigned may withdraw

his consent to the publication of this information via the public website by sending a

request to the competent authorities responsible for the registration.

.................................................................................................................................................

Place, date, signature of authorised signatory, name and job title

7. Box for official use by competent authority

The applicant is registered under the following number:

Registration

Number................................................................................................................

Date of registration..................................................................................................................

Date from which the registration is valid ...............................................................................

Signature and stamp

................................................................................................................